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  • Article

    Fidelity Funds vs The Danish Ministry – CJEU Rules In Favour Of Taxpayers

    The UCITS has the status of Article 16C of the law on the assessment of income tax
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    New CRS And FATCA Legislation: A Real Change?

    In our November 2019 ATOZ blog (Upcoming FATCA - CRS Issues: What the Alternative Fund Industry Needs to Know), we noted that the Luxembourg tax authorities more frequently...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Pillar Two And DAC9: Luxembourg Adopts Law Easing Filing Obligations And Clarifies Treatment Of Deferred Taxes

    On 17 December 2025, the Luxembourg Parliament enacted the law on the exchange of information with respect to "top-up tax information return" (the "DAC9 Law"), which transposes...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Public Country-By-Country Reporting Directive Adopted By The EU Council

    On 28 September 2021, more than five years after it was first tabled, the so-called "public Country-by-Country Reporting (CbCR) directive" was finally adopted by the EU Council under qualified majority voting.
    European UnionTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    EU Commission Finds No Illegal State Aid In The McDonald's Case

    On 19 September 2018, the EU Commission announced its decision in the McDonald's State Aid investigations. According to a press release the Commission has found that the non-taxation...
    GlobalTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    European Court Of Justice Rules On Spanish Withholding Tax On US RICs

    The European Court of Justice has ruled on whether a foreign tax credit mechanism can neutralise discriminatory withholding tax treatment for US Regulated Investment Companies receiving dividends from Spanish listed companies. The Spanish Supreme Court must now determine if theoretical neutralisation at shareholder level can ever be achieved in practice, given the exceptionally high evidentiary bar set by the CJEU.
    GlobalTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    The Bahamas, Belize, The Seychelles & The Turks And Caicos Islands Removed From The EU List Of Non-cooperative Tax Jurisdictions

    On 26 February 2024, the new list of non-cooperative jurisdictions for tax purposes (the "Blacklist") was published in the Official Journal of the European Union.
    GlobalTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    ATOZ Insights - May 2025

    As spring is upon us, the time has come to present our latest edition of our Insights, highlighting recent developments from the Grand Duchy, at European level, and in the Middle East over the past few months.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    CJEU Decides In Danish Cases Relating To Beneficial Ownership

    On 26 February 2019, the Court of Justice of the European Union ("CJEU") issued its decisions in six cases which deal with the interpretation of the Parent-Subsidiary Directive ("PSD") and the Interest & Royalties Directive ("IRD", together the "Directives").
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    DAC6 – Luxembourg Implements The New Reporting Obligations Of Tax Intermediaries

    On Saturday 21 March 2020, the Luxembourg parliament passed the law implementing the Council Directive (EU) 2018/822 of 25 May 2018 ("DAC6") regarding the mandatory exchange of ...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    ECOFIN Council Reaches An Agreement On DAC8

    At yesterday's ECOFIN meeting, the EU Council agreed on a general approach regarding foreseen amendments to the directive on administrative cooperation in the area of taxation.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    EU List Of Non-Cooperative Jurisdictions For Tax Purposes Confirmed By The EU Council

    During today's ECOFIN meeting, the EU Council has reaffirmed the EU list of noncooperative jurisdictions for tax purposes ("Blacklist").
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    The Amended Luxembourg Tax Consolidation Regime: Improvements Still Needed

    The 2021 budget law dated 19 December 2020 introduced a new provision dealing with the tax consolidation regime with effect as from tax year 2020.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    New Rules For EU Cross-border Conversions And Divisions Of Companies

    Yesterday, the law of 17 February 2025 (the "New Law") transposing the Directive (EU) 2019/2121 of the European Parliament and of the Council of 27 November 2019 (the "Mobility Directive")...
    LuxembourgCorporate/Commercial Law
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    2019 Tax Forecasts

    The ratification procedures of the new France-Luxembourg tax treaty and the Multilateral Convention to Implement Tax Treaty Related Measures to Prevent BEPS ("MLI") ...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    2020 Corporate Tax Returns: More Tax Rules, More Reporting, Time For Action!

    On 4 May 2021, the Luxembourg tax authorities informed Luxembourg taxpayers about the release of the corporate tax forms and related appendices in respect of tax year 2020.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Corporate Tax Reform 2019 – Part II

    On 5 March 2019, the 2019 budget draft law was presented to Parliament.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Luxembourg Government Submits Draft Law Introducing A Single Tax Class For Individual Taxpayers From 2028

    On 6 January 2026, the Luxembourg government released draft law No. 8676 (the "Draft Law") introducing a single tax class for income taxation...
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Tax Treatment Of Contributions To Account 115: Decision Of The Luxembourg Tribunal

    On 11 May 2021, the Luxembourg Administrative Tribunal ruled on whether contributions to "account 115" have to be taken into account when computing the acquisition price of a shareholding for the application of the participation exemption regime.
    LuxembourgTax
    Atoz Tax Advisers
    Atoz Tax Advisers
  • Article

    Apple Case: EU Judges Confirm That The European Commission Had It Wrong

    On 15 July 2020, in the Apple case, the EU judges (General Court) concluded for the second time in less than one year that the EU Commission failed to demonstrate that by issuing a tax ruling dealing with transfer pricing matters, ...
    European UnionTax
    Atoz Tax Advisers
    Atoz Tax Advisers

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